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Cigna's 'Bolt-On' Deals Could Target Smaller Health Insurers or Providers

"The Cigna Group appears to have given up on a big acquisition like the health insurance giant Humana ... [T]he company will now 'consider bolt-on acquisitions.' This could mean Cigna will look into purchases of smaller health insurers where the company isn't a dominant player ... or look to add health plans where the company is strong such as commercial health insurance like individual plans sold under the [ACA] as well as employer coverage."

Eleventh Circuit Asked to Revisit Exhaustion Requirement for ERISA Fiduciary Claims

"The plaintiffs-appellants assert that en banc review should be granted because it 'will [] further ERISA's goals of establishing a uniform regulatory regime over employee benefit plans.' They point out that 'a total of seven other circuits have rejected an exhaustion requirement for fiduciary breach and statutory claims under ERISA' and argue that if the case had of been brought in 'virtually any other circuit, Plaintiffs would have been permitted to proceed on the merits.' " [Bolton v. Inland Fresh Seafood Corp. of Am., Inc., No. 24-10084 (11th Cir. Oct. 15, 2025; pet. for rehearing filed Nov. 5, 2025)]

2026 Open Enrollment Checklist

"To prepare for open enrollment, employers that sponsor health plans should be aware of compliance changes affecting the design and administration of their plans for plan years beginning on or after Jan. 1, 2026. These changes include limits adjusted for inflation each year, such as the Affordable Care Act’s (ACA) affordability percentage and cost-sharing limits for high-deductible health plans (HDHPs). Employers should review their health plans’ design to confirm that they have been updated, as necessary, for these changes."

Eleventh Circuit Addresses ERISA Exhaustion Requirement

"The concurrence written by Circuit Judge Adalberto Jordan, joined by Circuit Judge William H. Pryor, Jr., is noteworthy. They propose to convene en banc to 'consider overruling Mason v. Continental Group ... which imposed a judicially created and atextual administrative exhaustion requirement for fiduciary breach and statutory claims under ERISA ... ' In the concurrence, Judge Jordan points out that the Eleventh Circuit is the only circuit with a mandatory exhaustion requirement and that the majority of circuits have held that 'plaintiffs asserting fiduciary-breach statutory claims under ERISA do not have to exhaust administrative remedies.' " [Bolton v. Inland Fresh Seafood Corp. of Am., Inc., No. 24-10084 (11th Cir. Oct. 15, 2025)]

Statutory Claims in the Eleventh Circuit: The Beginning of the End for Exhaustion?

"The plaintiffs contend that the defendants caused the plan to overpay for the stock by tens of millions of dollars ... [and] sought equitable relief ... [P]laintiffs contended that [1] they had no obligation to exhaust the plan's internal appeals, and [2] assuming such an obligation existed, they should be excused from that requirement.... The Eleventh Circuit began by acknowledging that while '[a]ll circuits require exhaustion in the ERISA context,' the Eleventh Circuit was special. 'Where we diverge is in our application of the exhaustion requirement to statutory violation claims.' " [Bolton v. Inland Fresh Seafood Corp. of Am., Inc., No. 24-10084 (11th Cir. Oct. 15, 2025)]

Eleventh Circuit Ruling Could Unravel Strict ERISA Exhaustion Rule

"A recent Eleventh Circuit decision opens up a route for overturning the appellate court's strictest-in-the-nation precedent requiring administrative exhaustion of all claims brought under [ERISA], ... given that two judges in a panel concurrence advocated for such action following en banc review." [Bolton v. Inland Fresh Seafood Corp. of Am., Inc., No. 24-10084 (11th Cir. Oct. 15, 2025)]

Eleventh Circuit Reaffirms Strict ERISA Exhaustion Requirement for Fiduciary-Breach Claims

"[T]he court emphasized that exhaustion applies 'across the spectrum of ERISA claims' -- including those alleging statutory violations or fiduciary breaches. While acknowledging that most other circuits do not require exhaustion for statutory ERISA claims, the Eleventh Circuit reaffirmed its unique position, holding itself bound by Mason until abrogated by the Supreme Court or by the court en banc." [Bolton v. Inland Fresh Seafood Corp. of Am., Inc., No. 24-10084 (11th Cir. Oct. 15, 2025)]

Advanced Primary Care Can Transform Employee Health: A Case Study

"[W]ith this new Advanced Primary Care model, employees enjoy easy, on-site access to care, at times that work with their schedules, and a location that is convenient for them. No complicated scheduling systems or insurance red tape -- just care when they need it."

PCORI Fees Due July 31, 2025

"Form 720 and full payment of the PCORI fees are due by July 31 of each year, and generally cover plan years that end during the preceding calendar year. For plan years ending in 2024, the PCORI fees are due by July 31, 2025."

IRS Eases Reapproval Burden for Substitute Mortality Tables in 2026

"[Rev. Proc. 2025-21] simplifies the rules for certain retirement plans needing to reapply for approval of their custom mortality tables ... The key change is a more flexible approach to determining when a new application is needed. If your plan's participant population hasn't changed much since your tables were first approved, you might not need to go through the approval process again in 2026."